Good afternoon, committee members. Thank you for the invitation to be here today.
I begin by offering my condolences to the family and friends of 14-year-old Athéna Gervais. It is unfortunate that this study is the result of her death, and it has raised challenging questions that must be answered.
From a public health perspective, there are two questions. One is what motivated her actions. The second is whether changes to the laws and regulations on alcohol sales would lessen the likelihood of that happening again.
The first question is challenging. Obviously, alcohol consumption is ubiquitous in our society, and so are the related harms. The chief public health officer of Canada in 2015 reported that almost 80% of Canadians drank alcohol. That data is from 2012. At least 3.4 million Canadians drank enough to be at risk of immediate harm, while 4.4 million are at risk of chronic health effects.
What is of more concern now is that 60% of our 15- to 19-year-olds reported having consumed alcohol, and among them almost 20% reported risky drinking behaviours that could result in short- and long-term impacts, as previously described.
From a public health perspective, I want to know why so many young people are engaging in risky drinking patterns so we can focus interventions on those issues. As with other psychoactive substances, problematic drinking is often a symptom of a larger emotional, physical, or mental health condition that needs to be addressed. As such, if governments want to see any meaningful progress, the Canadian Public Health Association believes that actions must be taken to understand the social pressures driving youth to consume alcohol and to provide them with the skills to make health-promoting choices.
Our second concern is whether current legislation for pre-mixed alcoholic beverages are adequate to limit access by an underaged drinker. Honestly, underage drinking has occurred since the establishment of minimum drinking ages, so it's unlikely we'll prevent its occurrence completely. However, there are steps that can be taken to reduce the consumption of pre-mixed drinks that combine high alcohol, caffeine, and sugar content, ingredients that are favoured by youth.
The Canadian Public Health Association supports the proposals included in Health Canada's notice of intent to amend the Food and Drug Regulations.
We specifically support the recommendation that restrictions be placed on the maximum percentage of alcohol allowed in a single-serving container to a level commensurate with a single serving of alcohol—as previously noted, the amount found in a bottle of beer.
We further support the recommendation on establishing a sweetness threshold that would trigger further restrictions, and we underscore that it must be done in consultation with key stakeholders and scientific experts.
Above and beyond these proposed regulations, the CPHA also supports the recommendations provided by the Canadian Centre on Substance Use and Addiction. I believe they spoke to you a day or so ago. They are proposing that manufacturers of alcoholic beverages have a sweetness threshold of no more than 5% spirit-based ethanol rather than ethanol obtained with fermentation of malt. As noted in their presentation, the regulation would have two positive effects for young Canadians.
First, products manufactured from ethanol are automatically subject to the higher excise duty imposed on spirits rather than lower duties imposed on beer, thereby reducing their affordability to young people.
Second, products manufactured from spirit-based ethanol cannot be sold in convenience or grocery stores, reducing their accessibility to young people.
The Canadian Public Health Association further encourages the federal government to closely collaborate with provinces and territories and other key stakeholders to implement some of the recommendations that were contained in our 2011 position statement on alcohol policies.
We actually called on all three levels of government to restrict alcohol marketing and sponsorship. This can be achieved by providing restrictions similar to those currently placed on alcohol products, so that these products are not seen as attractive to young people. We could also look at regulating all forms of alcohol marketing, particularly that provided through the Internet, social media promotions, and product placements.
For provincial and territorial governments, we recommend that they establish pricing systems based on a percentage of absolute alcohol in a standard drink, such that the higher the alcohol content, the higher the price. It would also be of benefit to provide a surtax on alcoholic beverages that are disproportionately consumed by youth.
In addition, we can look at restricting the sale of alcohol in convenience stores. Jurisdictions where such sales are already allowed should not permit further expansion of such sales. We should explore legal options on alcohol advertising, promotion, and sponsorship, particularly the type of sponsorship and advertising relating to the sale of products in licensed establishments.
As is often the case, our understanding of the harms associated with alcohol consumption is limited by under-resourced surveillance systems at the federal, provincial, and territorial levels. To develop effective interventions, we need to better track and understand the impacts of changes in access to alcohol, alcohol consumption patterns, and alcohol-related disease, injury, and social outcomes and their economic costs. To illustrate this point, we can often find alcohol sales data that is usually about a year old. However, our most recent data on societal costs are from 2002. We have to do better.
As I mentioned at the outset, alcohol consumption is ubiquitous in Canadian society, and the associated harms in 2002 cost society approximately $14.6 billion. Much greater attention and investment are required by all levels of government in order to reduce this burden. We need to look at the national alcohol strategy, which was originally published in 2007. There are 41 recommendations, some of which have been addressed, while others have not. A good starting point would be to update the strategy and have all levels of government committed to fully implementing its recommendations.
Thank you.